4 comments
This is awesome work, and a great transition plan!
Overall, HopeLink appreciates the level of detail and needs considered by this publication and has few concerns about the stated plans.
4.2 Assignment of Care
REQUEST: It is requested that providers who receive licenses to offer the new services be provided with the contact information of the MCO care coordinator for all of its members, by each MCO, when this step occurs.
5.3 Specialized Conversion Crosswalk
The idea that the specified active services (TDT, PSR, DBHDS-funded CSC) do not have a clear 1:1 transition and require a different process than the standard conversions is understood. However, some details are missing from this section that explain the process. The section states, “The CCMCO or Acentra identifies the appropriate service, in collaboration with the member an creates the authorization.” This lacks clarity as to what goes into determining the appropriate service. The following is requested.
REQUEST: Please explain/clarify how current PSR members will be determined to transition to Clubhouse versus CPST. Will this be based on the provider’s transition (for example, if a current PSR provider plans to offer Clubhouse, will all of the current PSR members be authorized to Clubhouse- and likewise, if a current PSR provider plans to offer CPST but NOT Clubhouse, will its current PSR members be authorized to CPST)?
REQUEST: Please clarify how MCOs will be notified that a member is currently receiving DBHDS-funded CSC.
5.5 Authorization Transition Principles
Given that MHSS is only authorized for 3-month periods currently, it is expected that nearly all MHSS-to-CPST converted auths will end in the period from July 1 to September 30, 2027. This section states that a CANS Lifetime assessment be completed “by the end of the transitioned authorization.” This requirement will create a bottleneck of a concentrated number of assessments due within a 3-month time period not only for 2027, but for each subsequent year that these individuals remain in any Medicaid-funded mental health service, since the CANS-Lifetime cannot be completed early and still billed at the assessment rate. It is suggested that the impact on workflow and availability of licensed providers to complete assessments during a concentrated period, instead of spread out through the year, be considered.
REQUEST: please consider amending this requirement to require that the CANS Lifetime be completed at the time the individual’s annual Comprehensive Needs Assessment would normally be due, and consider determining continued service authorization at the current LON or adjusted LON on other relevant information, such as quarterly review of treatment plan and service utilization and engagement.
The Virginia Association of Community-Based Providers (VACBP) thanks DMAS for the opportunity to comment on the draft Member Transition Plan. These comments reflect input from VACBP's Member's Advisory Council. We support the plan's core principle that no member experiences a gap in medically necessary services. We also support converting authorizations without provider requests, a conservative Transitional Level of Need, and member free choice of provider. Our requests aim to make those commitments work in practice. 1. CONFIRM THE ASSESSMENT REQUIREMENT FOR NEW CLIENTS NOT IN LEGACY SERVICES Section 1.1 states that the CANS Lifetime will not be completed before July 1, 2027. The plan does not address individuals who are not already in legacy services. Members' working understanding is that providers will continue using the Comprehensive Needs Assessment (CNA), including to request CPST for new clients after July 1, 2027, until the CANS Lifetime is available. Please: - Confirm in writing that the CNA remains the required assessment for new admissions to legacy services through June 30, 2027, and for new CBHS admissions until the CANS Lifetime is required. - Confirm that clients admitted with a CNA late in spring 2027 will be added to the transition roster and converted. - State whether a CANS Lifetime completed before July 1, 2027 is valid and billable. - Define "recently active" authorization (Section 4.1). 2. PUBLISH THE CREDENTIALING CUTOFF AND PROTECT CONTINUITY WHEN DELAYS ARE OUTSIDE THE PROVIDER'S CONTROL Accrediting bodies are already lengthening their expected response times. VACBP has been notified of an increase from 3-6 months to 4-7 months. Please: - Publish the Section 5(2) cutoff date now. - Do not move members when a provider's application is complete and timely but credentialing or accreditation is still pending. - State the accreditation deadline as a calendar date, used consistently in all DMAS and DBHDS documents, rather than as "18 months." - Publish MCO credentialing turnaround standards for CBHS. 3. HOLD REFERRAL SOURCES, NOT PROVIDERS, TO NEUTRAL PROVIDER CHOICE Section 4.3.1 makes the CSB case manager the lead for provider selection, and many CSBs also provide CPST. Members also report that some MCO care coordinators have visited members' homes unannounced and enrolled them in MCO-offered supports that duplicate services they already receive. Members also report that some coordinators redirected primary care linkage the current provider had already arranged, without contacting that provider. Please: - Require CSB case managers and MCO care coordinators to present all qualified providers in a neutral way and to document the member's informed choice. - Require care coordinators to coordinate with the member's current providers. - Prohibit enrolling members in duplicative services. - Do not add new provider documentation requirements to achieve this. 4. REQUIRE REFERRAL-PATTERN REPORTING Please make the "recommended safeguard" in Section 8.2 a contract requirement, and publish the reporting by region and by service. MCOs hold providers accountable, and the same transparency should apply to MCOs. Please also: - Define the auto-assignment outreach window (Section 6.3). - Notify the current provider before any member is auto-assigned away from it. 5. ASSIGN RESPONSIBILITY FOR THE TRANSITION ROSTER SO NO MEMBER FALLS THROUGH THE CRACKS Members find the roster process, as written, difficult to carry out in practice. As we understand it, the MCO care coordinator completes a service authorization for each active member. That authorization extends through September 30, 2027, or to the original end date if later. CPST starts no lower than Tier 2 / LON 4, about 5 hours per week (Section 5.5; Attachment 1). The plan relies on the coordinator but does not say what happens if a member is missed. Please: - Name the entity responsible for the roster and for notifying providers. State whether providers will receive one statewide list or a list from each MCO. Deliver it at least 60 days before go-live, showing each member's service, Transitional LON, units, end date, and care coordinator contact information. - Confirm that converted authorizations follow existing authorizations and are issued to the current provider. Explain how credentialing status, including out-of-network providers, changes this. Notify the member and provider before any change. Ensure no member is encouraged to change health plans because of a provider's network status. - State which provider-choice options members will be offered, and who is responsible for offering them. - Identify the options, supports, and escalation contact for members who are not on the roster. - Base the 90-day acuity adjustment on DMAS-wide claims data rather than a single plan's records, and allow providers to submit supporting evidence. Members report that MCOs currently deny authorizations because a hospitalization occurred before the member joined the plan. A universal service authorization request across all MCOs would help address this. - Add a backstop. DMAS should reconcile each MCO's roster against claims before go-live, and providers should have a way to flag missing members. Any member with an active legacy authorization on June 30, 2027 and no converted authorization on July 1, 2027 should receive an automatic bridge authorization at Tier 2 / LON 4. - If the CANS Lifetime is not available when a transitioned authorization ends, confirm that renewals may be based on the CNA with no gap in services. 6. SPREAD OUT THE CANS WORKLOAD Most converted authorizations end September 30, 2027, which concentrates assessments into a single quarter every year. Please: - Allow staggered and early CANS completion without losing H0031 billing. - Confirm that no authorization will lapse while a timely request is pending. 7. PUBLISH THE SPECIALIZED CONVERSION RULES AND MISSING PARAMETERS Please: - Publish how TDT members will be placed in CPST-School or CPST-Community, and how PSR members will be placed in Clubhouse or CPST. - Address youth receiving both IIH and TDT, and youth receiving summer-only TDT. - Publish the Section 5.4 units and timeframes before Phase 2 notices. - Notify providers and families promptly if TDT implementation timing changes. 8. FINALIZE ATTACHMENT 1 Please: - Publish the unit bands. - Reconcile LON 6 (768 units), which matches the CANS Appendix "with psychotherapy" ceiling, while LON 4 and LON 5 do not. - State whether psychotherapy units are included in converted authorizations. - Include the flowchart referenced in the attachment. 9. DEFINE CONTINUITY EXTENSIONS Please define "continuity extensions" and publish the Section 8.1 metrics on a regular schedule through stabilization. VACBP appreciates DMAS's work on this plan and is glad to help share transition information with providers.
If the CANS Lifetime will not be completed before July 1, 2027, the plan does not address individuals who are newly entering services and are not already receiving legacy services. Will the Comprehensive Needs Assessment (CNA) remain the required assessment for admissions to legacy services through June 30, 2027, and new CBHS admissions until the CANS Lifetime becomes the required assessment? Will CANS Lifetime completed before July 1, 2027, be considered valid for authorization purposes and billable?
Because most authorizations appear to expire on September 30, 2027, it would be helpful to stagger completion of CANS assessments without loss of H0031 billing eligibility as well as that authorizations will remain active when renewal requests are submitted on time and remain under review. If the CANS Lifetime remains unavailable when an authorization expires, will authorization renewals continue using the CNA without interruption of services.
There is still some confusion on transition from legacy to new CBHS services, transition guidance regarding service transition would be preferred for further clarification on Therapeutic Day Treatment (TDT) participants transitioned into CPST-School or CPST-Community; Psychosocial Rehabilitation (PSR) participants transitioned into Clubhouse services or CPST; and Youth who receive summer TDT services to ensure smooth transition for individuals.